That has been precisely my contention from the beginning! Compare the parts to an SKS action, and then you'll see why I wonder.
The "operating rod" aka "tappet" would be what that part is defined as... and when compared to an AK, that part connected to the bolt carrier is indeed the "piston".
Now re-read that ATF letter. No mention of operating rod whatsoever!
SO... the way I see it, the real question is, do you:
a) assume the ATF mis-typed the letter and replace both parts to keep with the spirit of the law?
b) proceed on the current data and replace that which Tromix or Hotbarrel sells to keep with the letter of the law?
I think "B" for now.
Frankly, it is a trivial matter to replace the piston, and I know Hotbarrel could whip us up a batch in no time.
Therefore, if ever the ATF recants and produces amplified documentation, you could have the additional part(s) installed and ready to go before the next trip to the range!
IMHO. I'm sure others will disagree.